i-SAFE, Inc. Application for Safe Harbor #546345-00002

January 31, 2010

Submission Number:

546345-00002

Commenter:

Jan Iye

State:

IL

Initiative Name:

i-SAFE, Inc. Application for Safe Harbor

Children's Online Privacy Protection Rule-Safe Harbor Proposed Self-Regulatory Guidelines: i-SAFE, Inc. Application for Safe Harbor (Document ID FTC-2010-0008-0001) I (C) Requirement #7: Compliance/Enforcement A. Program Representatives: 1. It is unfair to place unnecessary cost of hiring a fulltime employee on website owners. So long as the guidelines are implemented by the licensee, it should not be iSAFE's concern, who within the organization is implementing it. However, for transparency purposes, the website may be asked to disclose the email/phone/snail mail of the dealing department, similar to the manner in which listed companies are required to disclose the name of their investor liaison officer. III. Complaint/Dispute Resolution (Internal and Third-Party) (c) (2) 2. When so many responsibilities are placed on the licensee, some responsibilities should also be placed on iSAFE, such as penalties (civil and criminal) if the websites certified by iSAFE and carrying the iSAFE batch are repeated offenders. In extreme cases, there should be legal provisions for removing iSAFE as the licensing authority and bringing in other NGOs (I have no doubt, other NGOs will be more than willing to provide, equal to if not better services than what is currently being promised by iSAFE) This has to be done for the iSAFE badge to carry credibility. After all, who will respect a licensor, whose performance and validation process is not above question. 3. Disclosure necessary for the amount that iSAFE would charge for each of these certification which the licensee can display at its website, along with the iSAFE badge, as well as being disclosed prominently on iSAFE sight. This disclosure is necessary for the public to know that this certificate is what it stands for---a paid audit like any, by an independent agency for a price. Otherwise, members of the public may think it is being directly endorsed by the Congress. Janiye http://howtoblogformoney.net